DISH also touts potential job creation, emphasizing the fact that the company is prepared to spend “billions of dollars on infrastructure” and “employ tens of thousands of Americans.”

Although DISH’s spectrum holdings in the 2 GHz band were originally intended for satellite use, operators using that spectrum are allowed to also use it for an “ancillary” terrestrial network. DISH is seeking a relaxation of certain requirements related to the terrestrial network, such as a requirement that all handsets support both terrestrial and satellite communications.

The FCC is expected to give DISH what it wants. For example, the commission already has proposed renaming the 2 GHz band. Currently known as “mobile satellite spectrum,” the new name is “AWS-4,” highlighting the fact that the spectrum is adjacent to existing AWS spectrum that can support terrestrial 4G services.

DISH’s filing comes amid rumors that the company has bought $350 million in LightSquared debt and may try to acquire additional satellite spectrum from LightSquared, which has filed for bankruptcy protection. LightSquared’s spectrum is near the global positioning band and the company’s plans to use the spectrum for a terrestrial network were nixed because of concerns that a terrestrial service would interfere with GPS equipment.